The Records Disposition
Authority Policy
of the
University of South Alabama
January 2004
Prepared by Dr. Richard J. Wood and Mr. Ken Davis
TABLE OF CONTENTS
Section
Page No.
1. Overall Management of Records at USA
1
2. Creation, Maintenance, and Protection of Records
1
3. Public Access to Records
2
4. Definitions
3
5. Organization of Records
4
6. Storage of Records
4
7. Destruction of Copies & Transitory or Duplicate Records
5
8. Transfer of Records to USA Archives
5
9. Destruction of Temporary (Non-Permanent) Records
6
10. Disposition and Retention of Electronic Records
6
11. Disposition and Retention Schedule
7
Public Universities RDA Requirements
(Reproduced as issued by the State Records Commission)
3-1 – 3-24
1
1.
Overall Management Of Records At USA
This policy covers the creation, maintenance, and disposition of
records (records management) at the University of South Alabama (USA).
USA is committed to maintaining its records in an efficient and accessible
manner as a vital source of information for its employees, as well as the
state’s citizens. Accordingly, President V. Gordon Moulton in April 2003
appointed two individuals as USA’s Record Officers:
•
Dr. Richard Wood, Dean of University Libraries, and
•
Mr. Ken Davis, Assistant Vice President for Financial Affairs and
Director of Tax Accounting
They will oversee records management policies, procedures, and practices
at USA (except for hospital patient records) and carry-out the provisions
of the Code of Alabama 1975, Sections 36-12 and the “Functional
Analysis & Records Disposition Authority” (hereafter called RDA) for
Public Universities of Alabama issued by the State Records Commission
and administered by the Alabama Department of Archives and History
(ADAH).
2.
Creation, Maintenance, & Protection of Records
Each USA employee is required by law to create, maintain, and
protect the records that document the operations of their offices according
to state law (see above). Employees of USA should be aware of the RDA
because it is used to make decisions regarding the retention and
disposition of records, regardless of format. E-mail, spreadsheet, wordprocessed and other electronic documents, files, and databases must be
retained for the same time period as their paper equivalents. Records
covered by the RDA are to be retained and protected by the custodian of
those records until the retention period has expired. When the retention
period has been satisfied, the records should be disposed of in the
appropriate manner (see 9. Destruction of Temporary (Non-permanent)
Records). It is the responsibility of every state employee, therefore, to
2
follow RDA retention schedules for the records in their custody, as well as
ensure that any personal copies of official records are destroyed or
transferred as outlined in the RDA. All employees are also responsible for
reporting any actual or threatened loss or removal of records to the agency
records officer.
To safeguard records in large departments, record custodians may
find it advisable to develop a “check-out” or tracking system when anyone
removes a record from a file drawer, storage box, or storage room. Record
custodians may also want to send out reminders to colleagues, train new
employees about records management, and require employees to attend
training sessions.
3.
Public Access To Records
USA’s operational records are open to public inspection by law (Code
of Alabama 1975, Section 36-12-40) unless otherwise restricted. It is
assumed that requests may be made during normal business hours
(Monday through Friday, 8:00 a.m. through 5:00 p.m., or as posted in
individual offices at USA). There are, however, some types of documents
that offices can restrict public access to as follows:
•
medical patient records
•
employee records
•
student records
•
library circulation records
•
fragile or brittle records
Administrators or records custodians who are not sure about the
confidentiality or privacy of records are encouraged to talk the Records
Officer, Personnel Relations, or the University Attorney as appropriate.
The ultimate authority on questions of this nature is most likely to be the
University Attorney, Ms. Jean W. Tucker, 0131 AD (460-6294).
3
4.
Definitions
A Record is any paper document, e-mail message, file, video, audio tape,
microfilm, microfiche, computer disk, or other communication that is created or
acquired by an employee of USA in the course of conducting his or her job; such
records under state law belong to the government, not the employee. It is
important to recognize that every record does NOT have to be retained. The
Record Copy or Copy of Record is the document, tape, video, etc., that the
university recognizes as the official copy; it must be retained and destroyed
according to this RDA Policy. Other records may be shredded or destroyed.
Records Management at USA refers to all of the policies and procedures with
respect to organizing, filing, maintaining, transferring, preserving, deleting, or
destroying any document, publication, report, file, video or audio tape, electronic
media, microfiche or film, or other communication in any format. USA’s Record
Officers are Richard Wood and Ken Davis. USA’s Record Custodians are the
employees designated by administrators across campus to maintain office records
in accordance with the RDA.
Permanent Records at USA include any records that document state
business created prior to 1900 and the following: Vital Records such as birth &
death certificates, student recruitment materials and records (3-2), student and
faculty/staff handbooks (3-3, 14); course and curriculum records (3-3), USA
Archive collections and records/files (3-4), student publications (3-7), grade
sheets and statistics (3-11), graduation lists (3-11), individual student academic
records (3-12), Board of Trustees minutes and files of the President, final budget
and financial reports and documentation (3-17), accreditation records and final
assessment reports (3-15), minutes of standing and ad-hoc committee minutes (314), university publications and certain publicity (3-15), certain athletic records
(3-8), and all final and annual reports of all offices. “Permanent” means to retain
forever. USA’s Records Officer should be notified if any permanent records have
been destroyed, lost, or stolen.
4
Temporary Records at USA are all other non-permanent records that
document state business and are listed in the RDA. Their retention period varies
greatly from “useful life” to 50 or more years. Temporary records may be kept
longer than the published retention period if there is a good reason such as a court
case, grievance, or other administrative matter.
5.
Organization of Records
All records, including those in non-paper formats such as electronic or
microfilm, should be organized and filed “properly”—and in a timely manner in
order to facilitate access by employees of the unit or department. “Properly”
means filed in a logical, systematic, and consistent manner so that an employee’s
successor or colleague(s) can locate documents that may be needed. While USA
has no universal filing requirements, some conventions make sense. If possible,
records of the same or similar retention period (correspondence for example)
should be filed together by date. If a filing system is complex, a printed list
showing how files are organized may be necessary. Input from co-workers may
help to establish a system that is understood and accepted.
To free up storage space, record custodians should establish
cutoff/closing periods for files after which they are boxed up and moved to
storage or removed from hard-drives and placed on tape, diskette, or CD-ROM.
Policies covering filing, records organization and storage are the responsibility of
each department’s or unit’s chief administrator. No university-wide guidelines
have been established because each office’s circumstances or records are likely to
be unique.
6.
Storage of Records
Each office will normally store all of its own temporary and permanent
records. However, see TRANSFER OF RECORDS TO USA ARCHIVES (8)
BELOW.
5
7.
Destruction of Copies & Transitory or Duplicate Records
There are a variety of records that any state employee may discard or destroy
without the permission of USA’s Records Officers. No forms need to be
completed to discard or destroy the following types of records:
•
Convenience
or
duplicate
copies
of
memorandum,
notices,
correspondence, reports, publications, or temporary records such as drafts
of such material kept solely for easy reference, short-term use, and internal
office purposes (so long as some other [usually originating] office
maintains the original record for the required retention period).
•
Catalogs, journals, and other publications received by you/your office
from other entities.
8.
Transfer of Records to USA Archives
Records with a retention period of “Permanent Record” are not to be
destroyed and normally are retained by the department, office, or division that
originated them. Otherwise, USA Archives is likely to be the designated storage
entity for most academic and administrative offices, but not for medical and
hospital records. Record Custodians must complete the Permanent Records
Transmittal Request, send it to Archives, and receive a reply before transferring
records to the Archives.
A similar form (Temporary Records Transmittal Request) is used to
transfer temporary records to the USA Archives. Special boxes of a certain size
are used for records transferred to USA Archives; failure to use the specified
boxes may result in a charge to the office sending the records. Call the Archives
for more information (434-3800).
In rare situations, records may also be transferred to the Alabama
Department of Archives and History when the university office no longer has an
administrative need for them. However, permission from the USA Records
Officer is necessary to do so because this option is one most departments can not
afford.
6
9.
Destruction of Temporary (Non-Permanent) Records
Once the retention period for temporary records has expired, the record
custodian or employee should complete a Records Destruction Notice and mail it
to the Records Officer. Permission to destroy records covered by this policy must
be obtained prior to actual destruction. Only the designated agency USA Records
Officers may authorize that the records are eligible for destruction by signing and
returning the Records Destruction Notice to the records custodian. Only then can
the records custodian or employee destroy those particular records.
No records are to be destroyed that are necessary for agency compliance with
requirements of the state Sunset Act, an agency audit, any legal notice, or
subpoena. Acceptable methods used at USA for destruction include the following:
•
discarding of records in the trash can or placing the material in a recycle
box when such records do not contain financial, personnel, or other
sensitive personal information that should be shredded. Most material
placed in the trash ends up in a landfill, while material placed in a recycle
box is recycled and produces revenue for the university. Please recycle all
paper and cardboard that you can.
•
shredding (required for financial data, personnel records, and sensitive
information)
There is no centralized office for shredding documents in most administrative
or academic offices at USA; most departments are responsible for their own costs
of shredding.
10.
Disposition and Retention of Electronic Records
Data or reports, regardless of source, licensing or ownership, generated by
USA employees may or may not constitute a record that must be retained
according to this RDA Policy. To keep from becoming inundated in a sea of
computer output, it is important to establish whether a computer generated output
or report is a record defined by this policy. When any computer generated output
becomes an integral part of, or attachment to, a record covered by this RDA
Policy, it presumably must be retained as part of that record for the designated
7
retention period. When any computer-generated output is used or gathered merely
as input (raw data for instance), or to draw conclusions, etc., it may not need to be
retained in most circumstances, particularly if it is database information that other
employees may access. If the computer output may be needed for audit, legal, risk
management, tax, or similar purposes, the chief administrator of the unit or
department or the Records Officer(s) may need to be consulted.
While the retention period for electronic records is the same as their paper
equivalent according to the RDA, their disposition may differ because of the way
they are stored in computer memory, magnetic tape, and other modes of storage.
It may be necessary or advisable, for instance, to print copies of e-mails,
spreadsheets, and correspondence and retain the paper copy as the official
document, or copy of record. Doing so allows the electronic document in paper
format to be filed or stored with other types of records in the same series.
Computer operating systems, hardware, and application software changes also
may make it practical to retain paper copies if the retention period is longer than
one to three years. It should be noted that printing an electronic copy of some
documents may alter its formatting or appearance. Every attempt should be made
to replicate the original before the electronic medium (tape or disc) is erased or
destroyed.
Retention of FRS Banner of similar computer system reports is normally
the responsibility of the requesting department or administrator. The Computer
Services Department (CSD) generally only processes reports requested by
departments by pulling certain data from a massive system database. The CSD
sends the report to the requestor, but does not retain such reports. Record
custodians, therefore, must normally retain all system reports requested by their
departments from the CSD for the required RDA retention period. The retention
requirements may be satisfied if the ability to create the report from the database
exists for the duration of the retention period. For example, data entered into the
Banner database pertaining to records of funds deposited outside the state treasury
must be retrievable in a legible format for at least three years after the end of the
fiscal year in which the data were created. If for any reason it is not possible to
8
use the database to satisfy this requirement, it is the responsibility of the
department or administrator originating the database entries to satisfy the
retention requirements by other means.
Certainly, it is not advisable to maintain most permanent records only in
an electronic media such as a disk or tape. Paper and silver-halide microfiche or
microfilm is considered acceptable for permanent records. In the rare instance that
paper copies are scanned for preservation, all retention and disposition provisions
of the RDA shall apply. Finally, when electronic copies are disposed of or
destroyed according to the RDA, the same notification and authorization policy
applies to them as it does the paper record.
11.
Disposition & Retention Schedule
The
RDA
or
retention
schedule
that
may
be
found
http://www.archives.state.al.us/officials/rdas/universities_aug05.pdf is
organized by agency function as follows:
a. Admitting/Expelling Students (Recruitment Records)
b. Conveying Knowledge (Curriculum/Library/Archives)
c. Advising and Assisting Students (Publications, Athletics, Student Life)
d. Enforcing Laws
e. Evaluating Performance (Grade related records and lists)
f. Researching (Research Project & Policy Records)
g. Administering Internal Operations and Resources
at